1. Introduction
1.1 Purpose
This policy sets out the procedure for raising a whistleblowing concern and the support and protection that is available to you when you do so.
1.2 Our commitment
Whistleblowing is one of the most effective ways of preventing and eliminating wrongdoing at work.
Royal Museums Greenwich recognises that raising a whistleblowing concern can be daunting. However, we encourage you to report concerns internally as soon as possible where you suspect wrongdoing. We are here to listen and will take all concerns that you raise seriously.
1.3 Definitions
This policy outlines what Whistleblowing is, the roles of those involved and support that is available to you. The policy works on the following principles:
- Whistleblowing is the act of reporting suspected wrongdoing or risk of wrongdoing relating to:
- a criminal offence;
- a failure to comply with a legal obligation;
- a miscarriage of justice;
- a risk to the health and safety of an individual;
- damage to the environment; or
- an attempt to cover up any of the above.
- It is not necessary for you to prove the wrongdoing. However, to be protected by whistleblowing laws against detrimental treatment or dismissal, you must believe that wrongdoing (related to one of the categories listed above) is being, has been, or is likely to be committed and that your disclosure is in the public interest. You must also be able to demonstrate that there are sufficient grounds for concern.
- You are invited to speak out against behaviours you witness, even if they are not directed at you.
1.4 Scope
This policy applies to all staff, including Trustees, Executive Directors, Heads of Departments, Line Managers, Staff and Volunteers. It also applies to Freelancers, Contractors and Stakeholders when at our sites or using our digital services, including situations that may involve members of the public ().
If your concern relates to a personal grievance that is not in the public interest (for example, an allegation of bullying or harassment, or an allegation that your contract of employment has been breached), you should raise it under our separate Grievance Procedure.
If you are unsure about whether your concerns are best dealt with under the whistleblowing policy or grievance procedure, please speak to your line manager or a member of the People and Culture team for further advice.
This policy does not form part of your contract of employment and we reserve the right to amend or withdraw it at any time.
1.5 Roles and Responsibilities
The Executive Committee and the Board of Trustees are responsible and accountable for this Whistleblowing Policy and Procedure.
All staff have a duty to report wrongdoing under the circumstances set out under 1.3.
Line managers have a responsibility to ensure that all employees are aware of the Whistleblowing Policy.
1.6 Support Available to Employees
Employee Assistance Programme
Emotional support is available to all employees through our Advice and Counselling Employee Assistance Programme called Vivup.
Employees can also speak to a Wellbeing Champion, Mental Health First Aiders, the People & Culture team, a Staff Group member (if the issue pertains to their remit) or our Trade Union, Prospect.
Confidentiality is essential so please be mindful of this when seeking support, or if someone confides in you – you should encourage them to raise the issue with either managers, Directors or People & Culture so everyone can be protected by a secure procedure.
2. The Process
2.1 Stage 1 - Raising a whistleblowing concern
If you have a genuine concern relating to any type of wrongdoing that is covered under this policy, you should raise it with your line manager. If your concern relates to your line manager, or for any reason you do not wish to approach your line manager, you should raise your concern with the Head of People and Culture or with the Head of Governance or one of the Directors.
You should raise your concern in writing, and we recommend you use our Form to raise a whistleblowing concern.
It is important that you set out clearly:
- the details of the suspected wrongdoing;
- the names of any individuals involved; and
- and what action (if any) you are seeking
In some cases, it may be necessary to ask you to attend a meeting to clarify the nature of your concern. This will be arranged as soon as possible. You may, if you wish, bring a colleague or a trade union representative with you to the meeting. Where it is considered appropriate, a member of the People and Culture team may also be present.
2.2 Stage 2 - Responding to your whistleblowing concern
The manager to whom you raise your concern will decide if an investigation is required and, if it is, the most appropriate person to conduct it. The relevant manager will write to you within 3 working days confirming that they are conducting an investigation and the timescale for completion.
The level of investigation and time this will take will vary depending on the nature of the suspected wrongdoing.
Following the investigation, the relevant manager will inform you in writing, as quickly as possible after completion of the investigation, of the outcome and any next steps or action that will be taken. While we aim to provide you with comprehensive feedback, in some cases this may not be possible, for example where data protection rules apply or there are sensitive issues that need to remain confidential.
2.3 Stage 3 - Appeal
If you are not satisfied with how your concern has been dealt with, you should appeal to the Head of People and Culture, the Head of Governance or one of the Directors and they will then appoint a more senior manager than the manager who handled the original concern to chair your appeal.
You must raise your appeal in writing. It is important that you set out clearly the grounds of your appeal, i.e. the basis on which you consider that your original concern has not been satisfactorily dealt with.
In some cases, it may be necessary to ask you to attend a meeting to clarify the nature of your appeal. This will be arranged as soon as possible. You may, if you wish, bring a colleague or a trade union representative with you to the meeting. Where it is considered appropriate, a member of the People and Culture team may also be present.
The relevant manager will consider your grounds for appeal and review the manner in which your original whistleblowing concern was handled. You will be informed in writing of the outcome as quickly as possible.
3. External complaints
If a member of the public wishes to report a suspected fraud or has any other concerns relating to financial probity at Royal Museums Greenwich, they should write to either the Head of Finance, the Head of Governance and Museum Records, or the Head of People and Culture at Royal Museums Greenwich, Park Row, Greenwich, London SE10 9NF or alternatively they can complete the online form.
4. Confidentiality and anonymity
We want you to feel comfortable about raising a whistleblowing concern openly and actively encourage you to do so.
Where you raise a whistleblowing concern openly, we will maintain your confidentiality as far as possible. If we need to identify your identity to anyone, we will notify you beforehand.
We encourage anonymous reporting over remaining silent. Although we will investigate any concern that is reported anonymously as best we can, an anonymous report is likely to be more difficult for us to investigate and we will not be in a position to provide you with any feedback.
5. Harassment and victimisation
You have the right not to be subjected to any detrimental treatment (including being unfairly penalised, disciplined or dismissed) because you have raised a whistleblowing concern.
If you raise a whistleblowing concern in accordance with this policy, we will ensure that you are treated with respect and provided with adequate support and protection.
If you are told not to raise or pursue a whistleblowing concern, or you believe that you have been subjected to detrimental treatment because you have raised a whistleblowing concern, you should report the matter to the Head of People and Culture, the Head of Governance or one of the Directors. Alternatively, you can raise it under our Grievance Procedure.
Any such behaviour will not be tolerated and will be treated as a disciplinary offence.
Equally, if we find that an individual has knowingly raised false allegations, this will also be treated as a disciplinary offence and will be dealt with under our disciplinary procedure.
6. Reporting a concern to an external body
This policy is intended to provide a route by which members of staff can raise concerns internally. However, if an employee is unhappy with the outcome of an investigation or if, for any reason they do not feel comfortable raising their concern internally, they are free to take the matter outside of the organisation to a prescribed person or body or to their Member of Parliament (MP).
The full list of prescribed persons and bodies can be found on the UK government website at gov.uk/government/publications/blowing-the-whistle. They include:
• HM Revenue & Customs
• the Comptroller and Auditor General
• the Director of the Serious Fraud Office
• the Charity Commission for England and Wales
• the Information Commissioner
• the Equality and Human Rights Commission
• the Health and Safety Executive
• the Care Quality Commission
• the Environment Agency
More information and support
Protect is the UK’s whistleblowing charity that aims to stop harm by encouraging safe whistleblowing. They provide a legal advice service offering free expert and confidential advice on how best to raise a concern and protection as a whistleblower.
Protect Advice Line: 020 3117 2520 or the Protect online form
UK government advice on ‘Whistleblowing for employees’
Confidential support is available for individual employees from the employee assistance programme and this may include counselling if appropriate, in addition to practical information and advice (see 1.6).